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The Secretary shall notify in writing the person described in section 6321 of the filing of a notice of lien under section 6323.

TL Fahring focuses on helping individuals and businesses with a wide variety of matters involving state, federal, and international taxation.

Collection Due Process ("CDP") hearings are crucial to taxpayers. Taxpayers have a right to a Collection Due Process hearing with the IRS Independent Office of Appeals

This post is a follow-up to my previous post in which I discussed some of the basics concerning Individual Retirement Accounts ("IRAs").

Freeman Law's "The Tax Court in Brief" covers every substantive Tax Court opinion, providing a weekly brief of its decisions in clear, concise prose.

In a recent Private Letter Ruling, the Internal Revenue Service determined that termination of a corporation's S election, due to the creation of more than one class of stock or due to trusts becoming...

United States citizens and residents[i] are subject to federal income tax on their worldwide income. For example, even if a United States citizen permanently relocates to a foreign country...

For years, section 962 was a relatively obscure tax-planning mechanism. The Tax Cuts & Jobs Act, however, changed that, pushing the so-called section 962 election into vogue.

Section 6721 provides the IRS with authority to impose civil penalties against taxpayer-employers who fail to timely file correct information returns (e.g., Forms W-2/W-3 and Forms 940/941).

It's that time of year again. Various football teams scramble at the end of the regular season for a chance at the playoffs.

In October 1977, representatives of Unilever United States, Inc. (Unilever) expressed an interest in acquiring National Starch and Chemical Corporation (National Starch), later named INDOPCO, Inc...

Federal case and after federal case continues to come out providing real-life examples of the pitfalls of filing a Streamlined Filing Compliance Procedure ("SFCP") with the IRS when the facts suggest willfulness...

Freeman Law's "The Tax Court in Brief" covers every substantive Tax Court opinion, providing a weekly brief of its decisions in clear, concise prose.

Howdy folks, and welcome back to the Texas Tax Roundup. This August was a barren wasteland of sun and heat, but the Comptroller still managed to wrangle up some interesting tax issues.

In 1916, the Texas Supreme Court articulated the procuring-cause doctrine, which is a default rule that applies when a valid agreement to pay a commission on sales of property or product does not address...

The branch profits tax is imposed on foreign corporations engaged in a U.S. trade or business through a branch, rather than a subsidiary.

U.S. parented corporations that have foreign operations conducted through a foreign legal structure have significant U.S. tax filing and reporting obligations.

If you follow financial and crypto news, there are good chances you're aware of the ongoing dispute between the SEC and Coinbase.